The Puerto Rico Court of Appeals ruled on July 31, 2026, in the case of Stephan Watts v. Topflight Services, LLC, affirming a lower court's decision to dismiss a contract dispute. The ruling affects the parties involved in the case, particularly Stephan Watts and Tropicalia Corp., who sought to hold Topflight accountable for alleged contract violations. This decision is significant as it clarifies the application of prescriptive periods in contract law.
In this case, Stephan Watts filed a lawsuit against Topflight Services, LLC, and its president, Jean Michael Huertas Santiago, on October 7, 2023. Watts claimed that Topflight breached a contract for restoration services on a property he owned, which he intended to rent out short-term. He alleged that Topflight abandoned the project and failed to meet the agreed-upon completion date, leading to additional costs for Watts to hire another contractor to finish the job. The case was assigned docket number TA2026AP00558.
The dispute began when Watts filed a complaint with the Department of Consumer Affairs (DACO) on August 23, 2022, regarding the service issues. However, DACO determined it lacked jurisdiction over the matter, prompting Watts to seek legal recourse through the courts. In his lawsuit, Watts sought damages for breach of contract and reimbursement for expenses incurred due to Topflight's alleged failures.
Topflight responded by denying the allegations and filed a counterclaim against Watts, asserting that any delays were due to hidden damages discovered during the restoration process. They also argued that Watts's claim was barred by the statute of limitations, which they contended was one year for extracontractual damages.
On April 14, 2026, the lower court ruled in favor of Topflight, dismissing the claims against them based on the prescriptive period. The court found that the events leading to the lawsuit occurred on July 5, 2022, and since the lawsuit was filed on October 7, 2023, it was not timely under the applicable laws. The court stated, "...we conclude that the applicable prescriptive period is four years for contractual claims, but the claims against Topflight were not sufficiently alleged to warrant a remedy. Thus, we confirm the dismissal of the action against Topflight."
The Court of Appeals, led by Judge RodrÃguez Flores, upheld the lower court's decision. The judges agreed that the claims against Tropicalia Corp., which Watts sought to include as a co-plaintiff, were also barred by the statute of limitations. They noted that the claims were not sufficiently connected to the original complaint to allow for retroactive application of the prescriptive period.
The ruling has important implications for future contract disputes in Puerto Rico. It reinforces the necessity for plaintiffs to be aware of the prescriptive periods applicable to their claims. The court's decision clarifies that claims must be filed within the designated time frame, and failure to do so can result in dismissal, even if the underlying allegations are valid.
This ruling may impact other parties involved in similar disputes, particularly those who may have claims against contractors or service providers. It emphasizes the importance of timely legal action and the need for clear documentation of contractual relationships and obligations.
Looking ahead, it is unclear whether the decision will be appealed to a higher court. The parties may consider their options, but the ruling from the Puerto Rico Court of Appeals sets a clear precedent regarding the application of prescriptive periods in contract cases. There are no related cases pending that could further clarify this issue at this time.











